vermont yankee, technical specifications proposed change ...technical specification 3.1.8...

SEntergy--

Entergy Nuclear Operations, Inc.Vermont YankeeP.O. Box 0250320 Governor Hunt RdVernon, VT 05354Tel 802 257 7711

Michael J. ColombSite Vice President

BVY 09-068

December 3, 2009

ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555

SUBJECT: Technical Specifications Proposed Change No. 288Scram Discharge Volume Vent and Drain ValvesVermont Yankee Nuclear Power StationDocket No. 50-271License No. DPR-28

Dear Sir or Madam:

In accordance with 1OCFR50.90, Entergy Nuclear Operations, Inc. (ENO) is proposing to amendOperating License DPR-28 for Vermont Yankee Nuclear Power Station (VY).

The proposed changes would revise the VY Technical Specifications (TS) to incorporate StandardTechnical Specification 3.1.8 "Scram Discharge Volume (SDV) Vent and Drain Valves" andassociated Bases of NUREG-1433, Revision 3, "Standard Technical Specifications GeneralElectric Plants, BWR/4," modified to account for plant specific design details.

ENO has reviewed the proposed amendment in accordance with 10CFR50.92 and concludes itdoes not involve a significant hazards consideration. In accordance with 10CFR50.91, a copy ofthis application, with attachments, is being provided to the State of Vermont, Department of PublicService.

Attachment 1 to this letter provides a detailed description and evaluation of the proposed change.Attachment 2 contains a markup of the current TS and Bases pages. Attachment 3 contains theretyped TS and Bases pages. Bases changes are provided for information only.

ENO requests review and approval of the proposed license amendment by December 1, 2010 anda 60 day implementation period from the date of the amendment approval.

There are no new regulatory commitments made in this letter.

If you have any questions on this transmittal, please contact Mr. David Mannai at 802-451-3304.

ou

BVY 09-068 / of 2

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 3, 2009.

Sincerely,

MJC/PLC

Attachments1. Description and Evaluation of the Proposed Changes2. Markup of the Current Technical Specifications and Bases Pages3. Retyped Technical Specifications and Bases Pages

cc: Mr. Samuel J. CollinsRegional Administrator, Region 1U.S. Nuclear Regulatory Commission475 Allendale RoadKing of Prussia, PA 19406-1415

Mr. James S. Kim, Project ManagerDivision of Operating Reactor LicensingOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionMail Stop 08C2AWashington, DC 20555

USNRC Resident InspectorEntergy Nuclear Vermont Yankee, LLC320 Governor Hunt RdVernon, Vermont 05354

Mr. David O'Brien, CommissionerVT Department of Public Service112 State Street - Drawer 20Montpelier, Vermont 05620-2601

BVY 09-068Docket No. 50-271

Attachment 1

Vermont Yankee Nuclear Power Station

Proposed Change 288

Description and Evaluation of Proposed Changes

BVY 09-068 / Attachment 1 / Page 1 of 5

1. SUMMARY DESCRIPTION

This evaluation supports a request to amend Operating License DPR-28 for Vermont YankeeNuclear Power Station (VY).

The proposed changes would revise the VY Technical Specifications (TS) to incorporate StandardTechnical Specification (STS) 3.1.8 "Scram Discharge Volume (SDV) Vent and Drain Valves" andassociated Bases of NUREG-1433, Revision 3, Standard Technical Specifications General ElectricPlants, BWR/4," modified to account for plant specific design details.

2. DETAILED DESCRIPTION

The proposed changes would revise the VY TS to incorporate STS 3.1.8 "Scram DischargeVolume (SDV) Vent and Drain Valves" and associated Bases of NUREG-1433, Rev. 3, modified toaccount for plant specific design details. The VY TS do not contain a Limiting Condition forOperation (LCO) related to the SDV vent and drain valves. VY Surveillance Requirement (SR)4.3.B.7 requires that the SDV vent and drain valves be checked open at least once per month (thisis equivalent to STS SR 3.1.8.1) and allows the valves to be closed intermittently for testing underadministrative control. All other surveillance testing of the SDV vent and drain valves is controlledby the VY Inservice Test (IST) program.

Specifically, the proposed changes are:

1. Proposed TS 3/4.3.F will incorporate the required actions and surveillance requirementscontained within STS 3.1.8 with the following changes to address plant specificconfiguration:

a. VY has only one pneumatically-operated vent valve per vent line by design. There isa check valve in each vent line that backs up the pneumatically-operated valve.Proposed SR 4.3.F.1 is written to specify that only the pneumatically-operated ventand drain valves are checked open monthly and proposed SR 4.3.F.3 is written tospecify that only the pneumatically-operated valves are subject to closure timetesting on receipt of a scram signal and subsequent opening on scram reset.

b. For consistency with the convention used in the VY TS, the terms STARTUP, RUNand HOT SHUTDOWN are used in lieu of MODES 1, 2 and 3, respectively. Theseterm equivalencies are consistent with Table 1.1-1 of NUREG-1433, Rev. 3.

c. The pneumatically-operated SDV vent and drain valve closure time of < [60]seconds in STS SR 3.1.8.3.a is replaced by a closure time of < 30 seconds. This isthe maximum time allowed by the VY IST program and is conservative with respectto the STS SR 3.1.8.3.a closure time.

d. The terms once per month and once per operating cycle are used as surveillancerequirement frequencies in lieu of 31 days and [18] months, respectively.

e. STS SR 3.1.8.2 requires the cycling of each SDV vent and drain valve to the fullyopen and fully closed position every 92 days. For the pneumatically-operated SDVvent and drain valves, this test is currently being performed on a quarterly basis.This test is performed on the check valves in each vent line during each refuelingoutage. Both tests are performed in accordance with the VY Inservice Testing (IST)


Program. SR 4.3.F.2 is written to continue performance of this SR in accordancewith the VY IST Program, SR 4.6.E.2.

f. Added "SDV" to LCO wording for clarity.

2. VY SR 4.3.B.7 is being deleted. New SR 4.3.F.1 captures the requirements to verify thepneumatically-operated SDV vent and drain valves are open at least once per month.

3. The Table of Contents is revised to add proposed TS 3/4.3.F.

3. TECHNICAL EVALUATION

The scram discharge volume (SDV) vent and drain valves are part of the control rod drive (CRD)system. The CRD system at Vermont Yankee Nuclear Power Station (VY) is a reactivity controlsystem which controls gross changes in core reactivity by incrementally positioning neutronabsorbing control rods within the reactor core in response to manual control signals. The CRDSystem is required to quickly shut down the reactor (scram) by rapidly inserting control rods intothe core in response to a manual or automatic signal.

The safety-related functions of the CRD system are:

a. The CRD System shall provide rapid control rod insertion in the core to shutdown thereactor. The basis for this function is to prevent violation of fuel damage limits for normaloperation and all abnormal transients.

b. The CRD System shall provide signals to the Reactor Protection System (RPS) to initiate ascram when water in the SDV is above a specified minimum level. The basis for thisrequirement is to ensure that the SDV will have adequate volume for a full core scramwhen required.

The SDVs are used to limit the loss of, receive and contain the reactor vessel water from all theCRDs during a scram. VY has two separate, independent SDVs, each with its own vent and drainlines. Each SDV receives approximately half of the CRD discharges. One SDV is located on thenorth side of the 252' level of the Reactor Building (RB) and the other is located on the south sideof the 252' level of the RB. Each drain line contains two pneumatically-operated valves connectedin series that drain to the RB equipment drain sumps. Each vent line contains a singlepneumatically-operated valve and a check valve in series and vents to the RB HVAC exhaustplenum. The check valves back up the pneumatically-operated valve and eliminate the spraying ofcontaminated water into the HVAC exhaust plenum upon scram reset as the same signal opensthe yent and drain valves simultaneously.

During normal plant operation, the discharge volumes are empty with all their pneumatically-operated drain and vent valves open. The SDV is isolated upon initiation of a scram by closing thepneumatically-operated SDV vent and drain valves. The pneumatically-operated SDV vent anddrain valves are operated by signals from the RPS to the pneumatically-operated SDV vent anddrain solenoid valves or by the venting of air from the scram valve pilot air header. Positionindicator switches on the pneumatically-operated vent and drain valves indicate valve position bylights in the Main Control Room.


The SDV vent and drain valves are designed to isolate the SDV when reactor water is dischargedto the SDV through the scram discharge header and allow free venting and draining of the SDVafter a scram. The SDV vent and drain valves are required to support the safety related rapidcontrol rod insertion function.

The single automatic (pneumatically-operated) vent valve configuration at VY differs from the twoautomatic vent valve configuration assumed in Standard Technical Specification (STS) 3.1.8"Scram Discharge Volume (SDV) Vent and Drain Valves" and associated Bases of NUREG-1433,Revision 3, "Standard Technical Specifications General Electric Plants, BWR/4." This difference inthe vent line configuration is reflected in the proposed SRs by specifying that the monthlyverification that each SDV vent and drain valve is open and the closure time measurement afterreceipt of a scram signal and subsequent reopening on, scram reset each operating cycle are onlyapplicable to the pneumatically-operated SDV vent and drain valves. The check valves in the ventlines are operability tested by leak testing and draining the SDV during each refueling outage. Thissurveillance is currently performed in accordance with the VY IST Program and would continue tobe performed in accordance with proposed SR 4.3.F.2.

The proposed amendment does not change any existing equipment operating requirements anddoes not adversely affect existing plant safety margins or the reliability of the equipment assumedto operate in the safety analysis. The proposed amendment adds LCOs and SRs for the SDV ventand drain valves from the STS, modified to account for plant specific design details, to the VY TS.The surveillance tests proposed to be added as new SRs are currently performed as part of the VYIST program. As such, there are no changes being made to safety analysis assumptions, safetylimits or safety system settings that would adversely affect plant safety as a result of the proposedamendment.

4. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION

The proposed changes would revise the Vermont Yankee Nuclear Power Station (VY) TechnicalSpecifications (TS) to incorporate Standard Technical Specification (STS) 3.1.8 "Scram DischargeVolume (SDV) Vent and Drain Valves" and associated Bases of NUREG-1433, Revision 3,"Standard Technical Specifications General Electric Plants, BWR/4," modified to account for plantspecific design details, by adding Limiting Conditions for Operation (LCO) and SurveillanceRequirements (SR) for the SDV vent and drain valves. The surveillance tests proposed to beadded as new SRs are currently performed as part of the VY Inservice Testing (IST) program.

Pursuant to 1 OCFR50.92, Entergy Nuclear Operations, Inc. has reviewed the proposed changeand concludes that the change does not involve a significant hazards consideration since theproposed change satisfies the criteria in 1OCFR50.92(c). These criteria require that operation ofthe facility in accordance with the proposed amendment would not (1) involve a significant increasein the probability or consequences of an accident previously evaluated; (2) create the possibility ofa new or different kind of accident from any accident previously evaluated; or (3) involve asignificant reduction in a margin of safety. The discussion below addresses each of these criteriaand demonstrates that the proposed amendment does not constitute a significant hazard.

The proposed change does not involve a significant hazards consideration because:

1. The operation of Vermont Yankee Nuclear Power Station (VY) in accordance withthe proposed amendment will not involve a significant increase in the probability orconsequences of an accident previously evaluated.

The proposed amendment does not impact the operability of any structure, systemor component that affects the probability of an accident or that supports mitigation of


an accident previously evaluated. The proposed amendment does not affect reactoroperations or accident analysis and has no radiological consequences. Theoperability requirements for accident mitigation systems remain consistent with thelicensing and design basis. Therefore, the proposed amendment does not involve asignificant increase in the probability or consequences of an accident previouslyevaluated.

2. The operation of VY in accordance with the proposed amendment will not create thePossibility of a new or different kind of accident from any accident previouslyevaluated.

The proposed change does not involve a physical alteration of the plant (no new ordifferent type of equipment will be installed) or a change in the methods governingplant operation. Thus, this change does not create the possibility of a new ordifferent kind of accident from any previously evaluated.

3. The operation of VY in accordance with the proposed amendment will not involve asignificant reduction in a margin of safety.

The proposed change ensures that the safety functions of the SDV vent and drainvalves are fulfilled. The isolation function is maintained by valves in the vent anddrain lines and by the required action to isolate the affected line. The ability to ventand drain the SDVs is maintained through administrative controls. In addition, thereactor protection system ensures that an SDV will not be filled to the point that ithas insufficient volume to accept a full scram. Maintaining the safety functions Jrelated to isolation of the SDV and insertion of control rods ensures that theproposed change does not involve a significant reduction in the margin of safety.The proposed amendment does not change the design or function of anycomponent or system. The proposed amendment does not impact any safety limits,safety settings or safety margins.

Therefore, operation of VY in accordance with the proposed amendment will not involve a

significant reduction in the margin to safety.

5. ENVIRONMENTAL CONSIDERATIONS

This amendment request meets the eligibility criteria for categorical exclusion from environmentalreview set forth in 1 OCFR51.22(c)(9) as follows:

(i) The amendment involves no significant hazards determination.

As described in Section 4 of this evaluation, the proposed change involves no significanthazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of anyeffluent that may be released offsite.

The proposed amendment does not involve any physical alterations to the plantconfiguration that could lead to a change in the type or amount of effluent release offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.


The proposed changes would revise the VY Technical Specifications (TS) to incorporateStandard Technical Specification (STS) 3.1.8 "Scram Discharge Volume (SDV) Vent andDrain Valves" and associated Bases of NUREG-1433, Revision 3, "Standard TechnicalSpecifications General Electric Plants, BWR/4." The surveillance requirements that areproposed to be added to the TS are currently controlled by the VY IST program inaccordance with VY SR 4.6.E; therefore, no new surveillance tests are proposed to beadded and hence no significant increase in individual or cumulative occupational radiationexposure will occur.

Based on the above, VY concludes that the proposed change meets the eligibility criteria forcategorical exclusion as set forth in 1OCFR51.22(c)(9). Pursuant to 1OCFR51.22(b), noenvironmental impact statement or environmental assessment need be prepared in connectionwith the issuance of this amendment.

6. REFERENCES

a) NUREG-1433, Revision 3, "Standard Technical Specifications General Electric Plants,BWR/4," dated March 2004.

BVY 09-068Docket 50-271

Attachment 2


Proposed Change 288

Markup of the Current Technical Specifications and Bases Pages

VYNPS

TABLE OF CONTENTS

Page No.

1.0 DEFINITIONS ................................... 1

LIMITING SAFETYSAFETY LIMITS SYSTEM SETTING

1.1 FUEL CLADDING INTEGRITY ............................ 6 2 2.1

1.2 REACTOR COOLANT SYSTEM ............................ 18 ... 2.2

LIMITING CONDITIONS OF OPERATION Page No. SURVEILLANCE

3.0 LIMITING CONDITIONS OF OPERATION andSURVEILLANCE REQUIREMENT (SR) APPLICABILITY... 19a ... 4.0

BASES 19c

3.1 REACTOR PROTECTION SYSTEM ......................... 20 ... 4.1

BASES 29

3.2 PROTECTIVE INSTRUMENT SYSTEMS .................... 34 4.2

A. Emergency Core Cooling System ................ 34 ... AB. Primary ContainmentlIsolation ................ 43 ... B

C. Reactor Building Ventilation Isolationand Standby Gas Treatment SystemInitiation ................................ 50 ... C

D. (Deleted) .. ............................ !.. 54 ... DE. Control Rod Block Actuation .................. 54 ... EF. Mechanical Vacuum Pump Isolation

Instrumentation ....... ..................... 58 ... FG. Post-Accident Monitoring Instrumentation.. 60 ... GH. (Deleted). ... ........................ ........ 64 ... HI. Recirculation Pump Trip

Instrumentation ........................... 64 ... I

J . (Deleted) ................................ 64 ... JK. Degraded Grid Protective System ............ 68 ... KL. Reactor Core Isolation Cooling System

Actuation ................................. 72 L

BASES 75

3.3 CONTROL ROD SYSTEM ............................ 81 ... 4.3

A. Reactivity Limitations ....................... 81 ... A

B. Control Rods .............................. 3 2 ... BC. Scram Insertion Times ......................... 85 ... CD. Control Rod Accumulators ..................... 87 ... D

E. Reactivity Anomalies .......................... 8 8 ... E

n ASES N9

Amendment No.-44, 4ý, 4-4, 9-ý , 4-64, 4-94, 2•-14 , _- -21, "ýb , -i

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3.3 LIMITING CONDITIONS FOROPERATION.

4.3 SURVEILLANCE REQUIREMENTS

4. Control rod patterns andthe sequence ofwithdrawal or insertionshall be establishedsuch that the rod dropaccident limit of280 cal/g is notexceeded.

5. Control rods shall notbe withdrawn for startupor refueling unless atleast two source rangechannels have anobserved count rategreater than or equal tothree counts per second.

6. If the abovespecifications are notsatisfied, an orderlyshutdown shall beinitiated and thereactor shall be in theHOT SHUTDOWN conditionwithin 12 hours.

(c) Out-of-sequencecontrol rods ineach distinct RWMgroup shall beselected and theannunciator of theselection errorsverified.

(d) An out-of-sequencecontrol rod shallbe withdrawn nomore than threenotches and the rodblock functionverified.

4. The control rod patternand sequence ofwithdrawal or insertionshall be verified tocomply withSpecification 3.3.B.4.

5. Prior to control rodwithdrawal for startupor during refueling,verification shall bemade that at least twosource range channelshave an observed countrate of at least threecounts per second.

6. Deleted

dmni a ye' co tr

lu e a' nd en

0 tea o e pel

n t . h eal esmesignd r/

r

1•

Amendment No. 4, •64, -1-, , P3e-3 84

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3.3 LIMITING CONDITIONS FOROPERATION


E. Reactivity Anomalies

The reactivity equivalent ofthe difference between theactual critical rodconfiguration and theexpected configuration duringpower operation shall notexceed 1% Ak/k. If thislimit is exceeded, thereactor will be shut downuntil the cause has beendetermined and correctiveactions have been taken ifsuch actions are appropriate.


During the startup testprogram and startupsfollowing refueling outages,the critical rodconfigurations will becompared to the expectedconfigurations at selectedoperating conditions. Thesecomparisons will be used asbase data for reactivitymonitoring during subsequentpower operation throughoutthe fuel cycle. At specificpower operating conditions,the critical rodconfiguration will becompared to the configurationexpected based uponappropriately corrected pastdata. This comparison willbe made at least everyequivalent full power month.

I

6

Amendment No. 3, 4-4--, -64,-9-39 88

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BASES: 3.3 & 4.3 (Cont'd)

7. P r'd'c e fi/at"on h t e cra Di ch ge ol me SD dr inhv nt vve4 a e i ai ed n e pen/pos ti n p ov ess uln e hav t V il be av 1a le o a ce t t e ters efc o inatheevnt f scrm

C. Scram Insertion Times

BACKGROUND

The scram function of the Control Rod Drive (CRD) System controlsreactivity changes during abnormal operational transients to ensurethat specified acceptable fuel design limits are not exceeded. Thecontrol rods are scrammed by positive means using hydraulic pressureexerted on the CRD piston.

When a scram signal is initiated, control air is vented from the scramvalves, allowing them to open by spring action. Opening the exhaustvalve reduces the pressure above the main drive piston to atmosphericpressure, and opening the inlet valve applies the accumulator orreactor pressure to the bottom of the piston. Since the notches in theindex tube are tapered on the lower edge, the collet fingers are forcedopen by cam action, allowing the index tube to move upward withoutrestriction because of the high differential pressure across thepiston. As the drive moves upward and the accumulator pressure reducesbelow the reactor pressure, a ball check valve opens, letting thereactor pressure complete the scram action. If the reactor pressure islow, such as during startup, the accumulator will fully insert thecontrol rod in the required time without assistance from reactorpressure.

APPLICABLE SAFETY ANALYSES

The Design Basis Accident (DBA) and transient analyses assume that allof the control rods scram at a specified insertion rate. The resultingnegative scram reactivity forms the basis for the determination ofplant thermal limits (e.g., MCPR). Other distributions of scram times(e.g., several control rods scramming slower than the average time withseveral control rods scramming faster than the average time) can alsoprovide sufficient scram reactivity. Surveillance of each individualcontrol rod's scram time ensures the scram reactivity assumed in theDBA and transient analyses can be met.

The scram function of the CRD System protects the MCPR Safety Limit(SL) (reference TS I.I.A, "Bundle Safety Limit (Reactor Pressure >800psia and Core Flow >10% of Rated)," and TS 3.1l.C, "Minimum CriticalPower Ratio (MCPR)") and the 1% cladding plastic strain fuel designlimit (reference specification 3.1l.A, "Average Planar Linear HeatGeneration Rate (APLHGR)"), which ensure that no fuel damage will occurif these limits are not exceeded. Above 800 psig, the scram functionis designed to insert negative reactivity at a rate fast enough toprevent the actual MCPR from becoming less than the MCPR SL, during theanalyzed limiting power transient. Below 800 psig, the scram functionis assumed to perform during the control rod drop accident(Reference 1) and, therefore, also provides protection againstviolating fuel damage limits during reactivity insertion accidents(Reference TS 3.3.B.3 and 3.3.B.4, regarding the Rod Worth Minimizerand control rod patterns). For the reactor vessel overpressureprotection analysis, the scram function, along with the safety/reliefvalves, ensure that the peak vessel pressure is maintained within theapplicable ASME Code limits.

Control rod scram times satisfy Criterion 3 of 10 CFR 50.36(c) (2) (ii).

Amendment No. L-5-, --44, BVY 99 !1i, BVY 01 40, 91

VYNPS



During each fuel cycle, excess operating reactivity varies as fueldepletes and as any burnable poison in supplementary control is burned.The magnitude of this excess reactivity may be inferred from thecritical rod configuration. As fuel burnup progresses, anomalousbehavior in the excess reactivity may be detected by comparison of thecritical rod pattern selected base states to the predicted rodinventory at that state. Power operation base conditions provide themost sensitive and directly interpretable data relative to corereactivity. Furthermore, using power operating base conditions permitsfrequent reactivity comparisons. Reactivity anomaly is used as ameasure of the predicted versus measured core reactivity during poweroperation. If the measured and predicted rod density for identicalcore conditions at BOC do not reasonably agree, then the assumptionsused in the reload cycle design analysis or the calculation models usedto predict rod density may not be accurate. If reasonable agreementbetween measured and predicted core reactivity exists at BOC, then theprediction may be normalized to the measured value. Requiring areactivity comparison at the specified frequency assures that acomparison will be made before the core reactivity change exceeds 1%Ak/k. Deviations in core reactivity greater than 1% Ak/k are notexpected and require thorough evaluation. One percent reactivity limitis considered safe since an insertion of the reactivity into the corewould not lead to transients exceeding design conditions of the ReactorSystem.

Amendment No. 91h

Insert 1


F. Scram Discharge Volume Ventand Drain Valves

1. Each scram discharge volume(SDV) vent and drain valveshall be OPERABLE when thereactor is in the STARTUP orRUN MODES

---------NOTES-------* Separate Condition entry is

allowed for each SDV vent anddrain line.

* An isolated SDV line may beunisolated under administrativecontrol to allow draining andventing of the SDV.

a. If there is one or more SDV ventor drain line with one valveinoperable, then isolate theassociated SDV line within 7days.

b. If there is one or more SDV ventor drain line with both valvesinoperable, then isolate theassociated SDV line within 8hours.

c. If Specifications 3.3.F.l.a or3.3.F. .b are not met then thereactor shall be in HOTSHUTDOWN within 12 hours.

4.3 SURVEILLANCEREQUIREMENTS


--NOTE---------Not required to be met on ventand drain valves closed duringperformance of SR 4.3.F.2.

Verify each pneumatically-operated SDV vent and drainvalve is open at least once permonth.

2. Cycle each SDV vent and drainvalve to the fully closed and fullyopen position in accordance withSpecification 4.6.E.2.

3. At least once per operating cycle,verify each pneumatically-operated SDV vent and drainvalve:

a. Closes in < 30 secondsafter receipt of an actualor simulated scram signaland

b. Opens when the actual orsimulated scram signal isreset.

Insert 2

F. Scram Discharge Volume Vent and Drain Valves

BACKGROUND

The pneumatically-operated Scram Discharge Volume (SDV) vent and drain valves arenormally open and discharge any accumulated water in the SDV to ensure that sufficientvolume is available at all times to allow a complete scram. During a scram, thepneumatically-operated SDV vent and drain valves close to contain reactor water. Thescram discharge volumes are used to limit the loss of and contain the reactor vessel waterfrom all the drives during a scram. These volumes are provided in the scram dischargeheader. There are two separate, independent SDVs, each with its own vent and drainlines. Each SDV receives approximately half of the CRD discharges. Each drain linecontains two pneumatically-operated valves connected in series that drain to the ReactorBuilding (RB) equipment drain sumps. Each vent line contains a single pneumatically-operated valve and a check valve.


The SDV vent and drain valves are designed to isolate the SDV when reactor water isdischarged to the SDV through the scram discharge header and allow free venting anddraining of the SDV after a scram. The SDV vent and drain valves are required to supportthe safety related rapid control rod insertion function.

Isolation of the SDV can also be accomplished by manual closure of the pneumatically-operated SDV valves. Additionally, the discharge of reactor coolant to the SDV can beterminated by scram reset or closure of the HCU manual isolation valves. The SDV ventand drain valves allow continuous drainage of the SDV during normal plant operation toensure that the SDV has sufficient capacity to contain the reactor coolant dischargeduring a full core scram. To automatically ensure this capacity, a reactor scram isinitiated if the SDV water level in the instrument volume exceeds a specified setpoint.The setpoint is chosen so that all control rods are inserted before the SDV has insufficientvolume to accept a full scram.

LCO

The OPERABILITY of all SDV vent and drain valves ensures that the SDV vent anddrain valves will close during a scram to contain reactor water discharged to the SDVpiping. Since the drain lines are provided with two pneumatically-operated valves inseries, the single failure of one valve in the open position will not impair the isolationfunction of the system. The vent line contains a single pneumatically-operated valve anda check valve as a backup. Additionally, the valves are required to open on scram reset toensure that a path is available for the SDV piping to drain freely at other times.

APPLICABILITY

In the STARTUP and RUN MODES, scram may be required; therefore, the SDV ventand drain valves, must be OPERABLE..In the HOT SHUTDOWN and COLDSHUTDOWN MODES, control rods are not able to be withdrawn since the reactor modeswitch is in shutdown and a control rod block is applied. This provides adequate controlsto ensure that only a single control rod can be withdrawn. Also, during the REFUELINGMODE, only a single control rod can be withdrawn from a core cell containing fuelassemblies. Therefore, the SDV vent and drain valves are not required to be OPERABLEin these MODES since the reactor is subcritical and only one rod may be withdrawn andsubject to scram.

REQUIRED ACTIONS

3.3.F. 1 is modified by a note indicating that a separate condition entry is allowed for eachSDV vent and drain line. This is acceptable, since the required actions for each conditionprovide appropriate compensatory actions for each inoperable SDV line. Complying withthe required actions may allow for continued operation, and subsequent inoperable SDVlines are governed by subsequent condition entry and application of associated requiredactions.

When a line is isolated, the potential for an inadvertent scram due to high SDV level isincreased. During these periods, the line may be unisolated under administrative control.This allows any accumulated water in the line to be drained, to preclude a reactor scramon SDV high level. This is acceptable since the administrative controls ensure the valvecan be closed quickly, by a dedicated operator, if a scram occurs with the valve open.

3.3.F.l.a

When one SDV vent Or drain valve is inoperable in one or more lines, the associated linemust be isolated to contain the reactor coolant during a scram. The 7 day completion timeis reasonable, given the level of redundancy in the lines and the low probability of ascram occurring while the valve(s) are inoperable and the line is not isolated. The SDV isstill isolable since the redundant valve in the affected line is OPERABLE. During theseperiods, the single failure criterion may not be preserved, and a higher risk exists to allowreactor water out of the primary system during a scram. Once the associated SDV line isisolated continued operation is permissible.

3.3.F.l.b

If both vent or drain valves in a line are inoperable, the line must be isolated to containthe reactor coolant during a scram. The 8 hour completion time to isolate the line is basedon the low probability of a scram occurring while the line is not isolated and unlikelihoodof significant CRD seal leakage. Once the associated SDV line is isolated continuedoperation is permissible.

3.3.F.L.b

If both vent or drain valves in a line are inoperable, the line must be isolated to containthe reactor coolant during a scram. The 8 hour completion time to isolate the line is basedon the low probability of a scram occurring while the line is not isolated and unlikelihoodof significant CRD seal leakage. Once the associated SDV line is isolated continuedoperation is permissible.

3.3.F.L.c

If any required action and associated completion time are not met, the plant must bebrought to a MODE in which the LCO does not apply. To achieve this status, the plantmust be brought to at least HOT SHUTDOWN within 12 hours. The allowed completiontime of 12 hours is reasonable, based on operating experience, to reach HOTSHUTDOWN from full power conditions in an orderly manner and without challengingplant systems.

SURVEILLANCE REQUIREMENTS

SR 4.3.F.1

During normal operation, the pneumatically-operated SDV vent and drain valves shouldbe in the open position (except when performing SR 4.3.F.2) to allow for drainage of theSDV piping. Verifying that each valve is in the open position ensures' that thepneumatically-operated SDV vent and drain valves will perform their intended functionsduring normal operation. This SR does not require any testing or valve manipulation;rather, it involves verification that the valves are in the correct position. The monthlyfrequency is based on engineering judgment and is consistent with the proceduralcontrols governing valve operation, which ensure correct valve positions.

SR 4.3.F.2

During a scram, the SDV vent and drain valves should close to contain the reactor waterdischarged to the SDV piping. Cycling each valve through its complete range of motion(closed and open) ensures that the valve will function properly during a scram. Thevalves are tested in accordance with the requirements of the Inservice Testing Program.

SR 4.3.F.3

SR 4.3.F.3 is an integrated test of the pneumatically-operated SDV vent and drain valvesto verify total system performance. After receipt of a simulated or actual scram signal, theclosure of the pneumatically-operated SDV vent and drain valves is verified. The closuretime of 30 seconds after receipt of a scram signal is based on the Design MaximumActuation Time. Similarly, after receipt of a simulated or actual scram reset signal, theopening of the pneumatically-operated SDV vent and drain valves is verified. The LogicSystem Functional Test in LCO 3.1 .A and the scram time testing of control rods in LCO

3.3.C overlap this surveillance to provide complete testing of the assumed safetyfunction. The operating cycle frequency is based on the need to perform this surveillanceunder the conditions that apply during a plant outage and the potential for an unplannedtransient if the surveillance were performed with the reactor at power. Operatingexperience has shown these components usually pass the surveillance when performed atthe operating cycle frequency; therefore, the frequency was concluded to be acceptablefrom a reliability standpoint.

BVY 09-068Docket 50-271

Attachment 3


Proposed Change 288

Retyped Technical Specifications and Bases Pages

VYNPS

TABLE OF CONTENTS

Page No.

1.0 DEFINITIONS ................................... 1

LIMITING SAFETYSYSTEM SETTINGSAFETY LIMITS

1.1 FUEL CLADDING INTEGRITY .......................

1.2 REACTOR COOLANT SYSTEM ........................

LIMITING CONDITIONS OF OPERATION

6

18

... 2.1

... 2.2

Page No. SURVEILLANCE

3.0 LIMITING CONDITIONS OF OPERATION andSURVEILLANCE REQUIREMENT (SR) APPLICABILITY...

BASES

3.1 REACTOR PROTECTION SYSTEM .....................

BASES

3.2 PROTECTIVE INSTRUMENT SYSTEMS .................

A. Emergency Core Cooling System .............B. Primary Containment Isolation .............C. Reactor Building Ventilation Isolation

and Standby Gas Treatment SystemInitiation ................................

D. (Deleted) .................................E. Control Rod Block Actuation ...............F. Mechanical Vacuum Pump Isolation

Instrumentation ..........................G. Post-Accident Monitoring Instrumentation..H. (Deleted) .................................I. Recirculation Pump Trip

Instrumentation ...........................J. (Deleted).................................K. Degraded Grid Protective System ..........L. Reactor Core Isolation Cooling System

Actuation ..................................

BASES

3.3 CONTROL ROD SYSTEM.............................

19a

19c

4.0

4.120

29

34

3443

505454

586064

646468

72

75

81

818285878888

4.2

A

B

CDE

F

G

H

I

J

K

L

4.3

A.

B.C.D.E.F.

Reactivity Limitations ....................Control Rods ...............................Scram Insertion Times .....................Control Rod Accumulators ..................Reactivity Anomalies ......................Scram Discharge Volume Vent and Drain Valves

ABCDEF

Amendment No.4-3, 44, 4, 4, 4-64, 4-9-, 2--4, 24-4, 2-2-4, 2-3-6 -i-

VYNPS



4. Control rod patterns andthe sequence ofwithdrawal or insertionshall be establishedsuch that the rod dropaccident limit of280 cal/g is notexceeded.

5. Control rods shall notbe withdrawn for startupor refueling unless atleast two source rangechannels have anobserved count rategreater than or equal tothree counts per second.

6. If the abovespecifications are notsatisfied, an orderlyshutdown shall beinitiated and thereactor shall be in theHOT SHUTDOWN conditionwithin 12 hours.

(c) Out-of-sequencecontrol rods ineach distinct RWMgroup shall beselected and theannunciator of theselection errorsverified.

(d) An out-of-sequencecontrol rod shallbe withdrawn nomore than threenotches and the rodblock functionverified.

4. The control rod patternand sequence ofwithdrawal or insertionshall be verified tocomply withSpecification 3.3.B.4.

5. Prior to control rodwithdrawal for startupor during refueling,verification shall bemade that at least twosource range. channelshave an observed countrate of at least threecounts per second.

6. Deleted

7. Deleted

,Amendment No. -4, 41, 2-1,233 84

VYNPS




The reactivity equivalent ofthe difference between theactual critical rodconfiguration and theexpected configuration duringpower operation shall not

exceed 1% Ak/k. If thislimit is exceeded, thereactor will be shut downuntil the cause has beendetermined and correctiveactions have been taken ifsuch actions are appropriate.


1. Each scram dischargevolume (SDV) vent anddrain valve shall beOPERABLE when the reactoris in the STARTUP or RUNMODES.--- -- -- -- NOTES - - - - -

" Separate Condition entry isallowed for each SDV ventand drain line.

" An isolated SDV line may beunisolated underadministrative control toallow draining and ventingof the SDV.


During the startup testprogram and startupsfollowing refueling outages,the critical rodconfigurations will becompared to the expectedconfigurations at selectedoperating conditions. Thesecomparisons will be used asbase data for reactivitymonitoring during subsequentpower operation throughoutthe fuel cycle. At specificpower operating conditions,the critical rodconfiguration will becompared to the configurationexpected based uponappropriately corrected pastdata. This comparison willbe made at least everyequivalent full power month.


-. ---------- NOTE ----------Not required to be met onvent and drain valvesclosed during performanceof SR 4.3.F.2.

Verify eachpneumatically-operatedSDV vent and drain valveis open at. least once permonth.

2. Cycle each SDV vent anddrain valve to the fullyclosed and fully openposition in accordancewith Specification4.6.E.2.

3. At least once peroperating cycle, verifyeach pneumatically-operated SDV vent anddrain valve:

a. Closes in < 30 secondsafter receipt of anactual or simulatedscram signal and

a. If there is one ormore SDV vent ordrain line with onevalve inoperable,then isolate theassociated SDV linewithin 7 days.

Amendment No. 4, 4-44, 4-", 444 88

VYNPS3.3 LIMITING CONDITIONS FOR

OPERATION4.3 SURVEILLANCE REQUIREMENTS

b. If there is one ormore SDV vent ordrain line with bothvalves inoperable,then isolate theassociated SDV linewithin 8 hours.

c. If Specifications3.3.F.l.a or3.3.F.l.b are not metthen the reactorshall be in HOTSHUTDOWN within 12hours.

b. Opens when the actualor simulated scramsignal is reset.

Amendment No. 88a

VYNPS


7. Deleted

C. Scram Insertion Times

BACKGROUND

The scram function of the Control Rod Drive (CRD) System controlsreactivity changes during abnormal operational transients to ensurethat specified acceptable fuel design limits are not exceeded. Thecontrol rods are scrammed by positive means using hydraulic pressureexerted on the CRD piston.

When a scram signal is initiated, control air is vented from the scramvalves, allowing them to open by spring action. Opening the exhaustvalve reduces the pressure above the main drive piston to atmosphericpressure, and opening the inlet valve applies the accumulator orreactor pressure to the bottom of the piston. Since the notches in theindex tube are tapered on the lower edge, the collet fingers are forcedopen by cam action, allowing the index tube to move upward withoutrestriction because of the high differential pressure across thepiston. As the drive moves upward and the accumulator pressure reducesbelow the reactor pressure, a ball check valve opens, letting thereactor pressure complete the scram action. If the reactor pressure islow, such as during startup, the accumulator will fully insert thecontrol rod in the required time without assistance from reactorpressure.


The Design Basis Accident (DBA) and transient analyses assume that allof the control rods scram at a specified insertion rate. The resultingnegative scram reactivity forms the basis for the determination ofplant thermal limits (e.g., MCPR). Other distributions of scram times(e.g., several control rods scramming slower than the average time withseveral control rods scramming faster than the average time) can alsoprovide sufficient scram reactivity. Surveillance of each individualcontrol rod's scram time ensures the scram reactivity assumed in theDBA and transient analyses can be met.

The scram function of the CRD System protects the MCPR Safety Limit(SL) (reference TS 1.1.A, "Bundle Safety Limit (Reactor Pressure >800psia and Core Flow >10% of Rated)," and TS 3.1l.C, "Minimum CriticalPower Ratio (MCPR)") and the 1% cladding plastic strain fuel designlimit (reference specification 3.1l.A, "Average Planar Linear HeatGeneration Rate (APLHGR)"), which ensure that no fuel damage will occurif these limits are not exceeded. Above 800 psig, the scram functionis designed to insert negative reactivity at a rate fast enough toprevent the actual MCPR from becoming less than the MCPR SL, during theanalyzed limiting power transient. Below 800 psig, the scram functionis assumed to perform during the control rod drop accident(Reference 1) and, therefore, also provides protection againstviolating fuel damage limits during reactivity insertion accidents(Reference TS 3.3.B.3 and 3.3.B.4, regarding the Rod Worth Minimizerand control rod patterns). For the reactor vessel overpressureprotection analysis, the scram function, along with the safety/reliefvalves, ensure that the peak vessel pressure is maintained within theapplicable ASME Code limits.

Control rod scram times satisfy Criterion 3 of 10 CFR 50.36(c) (2) (ii).

Amendment No. •-, -7 4-4, B- 99- !1!, ... 1 -4Q, •-4 ,1 91

VYNPS



During each fuel cycle, excess operating reactivity varies as fueldepletes and as any burnable poison in supplementary control is burned.The magnitude of this excess reactivity may be inferred from thecritical rod configuration. As fuel burnup progresses, anomalousbehavior in the excess reactivity may be detected by comparison of thecritical rod pattern selected base states to the predicted rodinventory at that state. Power operation base conditions provide themost sensitiveand directly interpretable data relative to corereactivity. Furthermore, using power operating base conditions permitsfrequent reactivity comparisons. Reactivity anomaly is used as ameasure of the predicted versus measured core reactivity during poweroperation. If the measured and predicted rod density for identicalcore conditions at BOC do not reasonably agree, then the assumptionsused in the reload cycle design analysis or the calculation models usedto predict rod density may not be accurate. If reasonable agreementbetween measured and predicted core reactivity exists at BOC, then theprediction may be normalized to the measured value. Requiring areactivity comparison at the specified frequency assures that acomparison will be made before the core reactivity change exceeds 1%Ak/k. Deviations in core reactivity greater than 1% Ak/k are notexpected and require thorough evaluation. One percent reactivity limitis considered safe since an insertion of the reactivity into the corewould not lead to transients exceeding design conditions of the ReactorSystem.

F. Scram Discharge Volume Vent and Drain Valves

BACKGROUND

The pneumatically-operated Scram Discharge Volume (SDV) vent and drainvalves are normally open and discharge any accumulated water in the SDVto ensure that sufficient volume is available at all times to allow acomplete scram. During a scram, the pneumatically-operated SDV vent anddrain valves close to contain reactor water. The scram dischargevolumes are used to limit the loss of and contain the reactor vesselwater from all the drives during a scram. These volumes are provided inthe scram discharge header. There are two separate, independent SDVs,each with .its own vent and drain lines. Each SDV receives approximatelyhalf of the CRD discharges. Each drain line contains two pneumatically-operated valves connected in series that drain to the Reactor Building(RB) equipment drain sumps. Each vent line contains a singlepneumatically-operated valve and a check valve.


The SDV vent and drain valves are designed to isolate the SDV whenreactor water is discharged to the SDV through the scram dischargeheader and allow free venting and draining of the SDV after a scram. TheSDV vent and drain valves are required to support the safety relatedrapid control rod insertion function.

Isolation of the SDV can also be accomplished by manual closure of thepneumatically-operated SDV valves. Additionally, the discharge ofreactor coolant to the SDV can be terminated by scram reset or closureof the HCU manual isolation valves. The SDV vent and drain valves allowcontinuous drainage of the SDV during normal plant operation to ensurethat the SDV has sufficient capacity to contain the reactor coolantdischarge during a full core scram. To automatically ensure thiscapacity, a reactor scram is initiated if the SDV water level in theinstrument volume exceeds a specified setpoint. The setpoint is chosenso that all control rods are inserted before the SDV has insufficientvolume to accept a full scram.

Amendment No. 91h

VYNPS

LCO

The OPERABILITY of all SDV vent and drain valves ensures that the SDVvent and drain valves will close during a scram to contain reactor waterdischarged to the SDV piping. Since the drain lines are provided withtwo pneumatically-operated valves in series, the single failure of onevalve in the open position will not impair the isolation function of thesystem. The vent line contains a single pneumatically-operated valve anda check valve as a backup. Additionally, the valves are required to openon scram reset to ensure that a path is available for the SDV piping todrain freely at other times.

APPLICABILITY

In the STARTUP and RUN MODES, scram may be required; therefore, the SDVvent and drain valves must be OPERABLE.

In the HOT SHUTDOWN and COLD SHUTDOWN MODES, control rods are not ableto be withdrawn since the reactor mode switch is in shutdown and acontrol rod block is applied. Also, during the REFUELING MODE, only asingle control rod can be withdrawn from a core cell containing fuelassemblies. Therefore, the SDV vent and drain valves are not required tobe OPERABLE in these MODES since the reactor is subcritical and only onerod may be withdrawn and subject to scram.

REQUIRED ACTIONS

3.3.F.l is modified by a note indicating that a separate condition entryis allowed for each SDV vent and drain line. This is acceptable, sincethe required actions for each condition provide appropriate compensatoryactions for each inoperable SDV line. Complying with the requiredactions may allow for continued operation, and subsequent inoperable SDVlines are governed by subsequent condition entry and application ofassociated required actions.

When a line is isolated, the potential for an inadvertent scram due tohigh SDV level is increased. During these periods, the line may beunisolated under administrative control. This allows any accumulatedwater in the line to be drained, to preclude a reactor scram on SDV highlevel. This is acceptable since the administrative controls ensure thevalve can be closed quickly, by a dedicated operator, if a scram occurswith the valve open. These controls consist of stationing a dedicatedoperator, with whom Control Room communication is immediately available,in the immediate vicinity of the valve controls.

3.3.F.l.a

When one SDV vent or drain valve is inoperable in one or more lines, theassociated line must be isolated to contain the reactor coolant during ascram. The 7 day completion time is reasonable, given the level ofredundancy in the lines and the low probability of a scram occurringwhile the valve(s) are inoperable and the line is not isolated. The SDVis still isolable since the redundant valve in the affected line isOPERABLE. During these periods, the single failure criterion may not bepreserved, and a higher risk exists to allow reactor water out of theprimary system during a scram. Once the associated SDV line is isolatedcontinued operation is permissible.

3.3.F.l.b

If both vent or drain valves in a line are inoperable, the line must beisolated to contain the reactor coolant during a scram. The 8 hourcompletion time to isolate the line is based on the low probability of ascram occurring while the line is not isolated and unlikelihood ofsignificant CRD seal leakage. Once the associated SDV line is isolatedcontinued operation is permissible.

Amendment No. 91i

i ' '

VYNPS

3.3.F. I .c

If any required action and associated completion time are not met, theplant must be brought to a MODE in which the LCO does not apply. Toachieve this status, the plant must be brought to at least HOT SHUTDOWNwithin 12 hours. The allowed completion time of 12 hours is reasonable,based on operating experience, to reach HOT SHUTDOWN from full powerconditions in an orderly manner and without challenging plant systems.

SURVEILLANCE REQUIREMENTS

SR 4.3.F.1

During normal operation, the pneumatically-operated SDV vent and drainvalves should be in the open position (except when performing SR4.3.F.2) to allow for drainage of the SDV piping. Verifying that eachvalve is in the open position ensures that the pneumatically-operatedSDV vent and drain valves will perform their intended functions duringnormal operation. This SR does not require any testing or valvemanipulation; rather, it involves verification that the valves are inthe correct position. The monthly frequency is based on engineeringjudgment and is consistent with the procedural controls governing valveoperation, which ensure correct valve positions.

SR 4.3.F.2

During a scram, the SDV vent and drain valves should close to containthe reactor water discharged to the SDV piping. Cycling each valvethrough its complete range of motion (closed and open) ensures that thevalve will function properly during a scram. The valves are tested inaccordance with the requirements of the Inservice Testing Program.

SR 4.3.F.3

SR 4.3.F.3 is an integrated test of the pneumatically-operated SDV ventand drain valves to verify total system performance. After receipt of asimulated or actual scram signal, the closure of the pneumatically-operated SDV vent and drain valves is verified. The closure time of 30seconds after receipt of a scram signal is based on the Design MaximumActuation Time. Similarly, after receipt of a simulated or actual scramreset signal, the opening of the pneumatically-operated SDV vent anddrain valves is verified. The Logic System Functional Test in LCO 3.1.Aand the scram time testing of control rods in LCO 3.3.C overlap thissurveillance to provide complete testing of the assumed safety function.The operating cycle frequency is based on the need to perform thissurveillance under the conditions that apply during a plant outage andthe potential for an unplanned transient if the surveillance wereperformed with the reactor at power. Operating experience has shownthese components usually pass the surveillance when performed at theoperating cycle frequency; therefore, the frequency was concluded to beacceptable from a reliability standpoint.

Amendment No. 91j

vermont yankee, technical specifications proposed change ...technical specification 3.1.8...

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